Privacy Policy

Lake Hollywood Homeowners Association (LHHA)

Privacy and ALPR Policy Effective Date: December 28, 2025

  1. Overview and Scope

The Lake Hollywood Homeowners Association (“LHHA,” “we,” “our,” or “us”) is a voluntary membership-based 501(c)(4) nonprofit mutual benefit homeowners association. This Policy governs the collection, use, and retention of data across all LHHA platforms.

Scope of Surveillance:

  • Public Areas Only: LHHA video and ALPR cameras are positioned to capture data strictly from public areas (e.g., public streets and intersections). No cameras are positioned to view private property, private residences, or non-public areas.

This policy is designed to comply with California state laws, including California Civil Code § 1798.90.5 et seq. (SB 34) regarding ALPR usage.

PART I: WEBSITE AND GENERAL DATA PRIVACY

  1. Information We Collect (Non-ALPR)
  2. Personal Information We collect information you voluntarily provide (e.g., name, address, email, phone number) when you register for membership, fill out forms on our Sites (www.LakeHHA.org and www.cityatrisk.la), or correspond with us via email.
  3. Website Usage Data & Cookies Our Sites use cookies and analytics tools to collect data such as IP addresses, browser types, and page visit history to improve site performance and community services. You may disable cookies in your browser settings, though this may affect Site functionality.
  4. General Video Surveillance (Non-ALPR)
  • Scope: Video footage from LHHA-operated security cameras that captures general situational views of public areas.
  • Retention: General video footage is retained for a maximum of two weeks (14 days).
  • Deletion: Footage is automatically overwritten after 14 days unless specifically retained for an active investigation or legal requirement.
  1. Data Sharing (General)

We do not sell or rent personal information. We share data only with:

  • Service Providers: Vendors assisting with Site operations or data storage.
  • Legal Compliance: When required by law (e.g., subpoenas).
  • Investigations: Strictly for the investigation of crime and violations of city law. This data is not used for enforcing LHHA community rules or any other private civil matter.

PART II: AUTOMATED LICENSE PLATE READER (ALPR) POLICY

  1. Authorized Purposes for ALPR System

The LHHA utilizes ALPR technology strictly for the following purposes:

  • Traffic & Commercial Vehicle Analysis (Principal Purpose): To count vehicles and monitor vehicle types in order to document excessive traffic volumes and the presence of oversize or commercial vehicles on area streets.
  • Community Safety: To enhance the safety and security of the Lake Hollywood community.
  • Crime Deterrence: To deter criminal activity and assist law enforcement in the identification and investigation of crimes.
  • Prohibited Uses: The ALPR system shall not be used for harassment, intimidation, monitoring individuals based on protected characteristics, enforcing HOA community rules or any other private civil matter.
  1. ALPR Information Collected

The ALPR system captures the following information from public areas only:

  • Vehicle Details: License plate number, make, model, body type, color, and identifying marks (e.g., bumper stickers, damage).
  • Context: Digital images of the vehicle, date, time, and GPS location of the capture.
  1. Data Retention and Destruction (ALPR)
  • Raw ALPR Data: Data containing personally identifiable information (license plate numbers, images, and vehicle attributes) is retained for 30 days. If not accessed for a specific investigation, it is automatically purged.
  • Investigative Retention: Data flagged as relevant to a specific criminal investigation or legal proceeding may be retained until the matter is resolved.
  • Anonymized Aggregate Data: Data that has been stripped of all personal identifiers (e.g., traffic counts, vehicle classification stats) may be retained for up to five (5) years for statistical and planning purposes.
  1. Authorized Users, Training, and Oversight
  • Authorized Users: Access to ALPR data is strictly limited to the LHHA President (or his/her designee) and the outside system administrator (if any).
  • Training: All authorized users must review this Privacy and ALPR Policy and receive training on the proper use and security of the system before being granted access.
  • System Monitoring: The LHHA conducts periodic audits of access logs to ensure the system is being used solely for authorized purposes. Unauthorized access or misuse will result in immediate revocation of access.
  1. ALPR Data Sharing and Law Enforcement

LHHA does not sell ALPR data.

  • No Automatic Sharing: ALPR data is not automatically transmitted to police, government agencies, or third parties.
  • No Real-Time Monitoring: The system does not check license plate data in real-time against law enforcement “Hot Lists.”
  • Law Enforcement Access: Data is shared with law enforcement agencies only upon receipt of a formal request accompanied by a valid case or complaint number.
  • Legal Process: Data may also be shared in response to a valid court order, subpoena, or warrant.
  1. Official Custodian

The Official Custodian of the ALPR system and its data is the current President of LHHA or his/her designee. The Custodian is responsible for ensuring compliance with this policy and applicable laws.

PART III: USER RIGHTS AND CONTACT

  1. Data Security

We maintain reasonable administrative, technical, and physical safeguards to protect all data, including encryption and access controls. However, no system is impenetrable, and we cannot guarantee absolute security.

  1. Communications and Opt-Out

By providing your contact information, you consent to receive communications from LHHA. You may opt out of non-essential emails at any time by contacting us.

  1. California Resident Rights

Residents may request information regarding the categories of personal data collected, correction of inaccuracies, or deletion of data not subject to mandatory retention.

  1. Contact Information

For questions regarding this policy or to report a privacy/ALPR concern: Email: Privacy@LakeHHA.Org

For general inquiries regarding LHHA operations or membership: Email: Info@LakeHHA.Org

ALPR/Camera Privacy Policy

Lake Hollywood Homeowners Association (LHHA)

Automated License Plate Reader (ALPR) Privacy and Usage Policy

Effective Date: September 1, 2025

  1. Purpose

The Lake Hollywood Homeowners Association (“LHHA,” “we,” or “us”) may use Automated License Plate Reader (ALPR) technology to enhance the safety, livability, and emergency preparedness of the Lake Hollywood neighborhood. This Privacy and Usage Policy is designed to ensure transparency and legal compliance with California Civil Code §§ 1798.90.5 – 1798.90.55 (commonly referred to as “SB 34”).

  1. Definition of ALPR and ALPR Information
    • ALPR Technology: A searchable computerized system that captures images of license plates and converts them into data using optical character recognition.
    • ALPR Information: Includes images, license plate numbers, time stamps, location data, and any metadata associated with those records.
  2. Primary Purpose of Data Collection

The ALPR system is deployed for the primary purpose of analyzing traffic into and out of the Lake Hollywood community in order to:

  • Measure and understand the volume of non-resident traffic
  • Identify traffic trends that may affect emergency response, wildfire risk, pedestrian and cyclist safety, and neighborhood tranquility
  • Support neighborhood-driven advocacy with the City of Los Angeles for traffic mitigation and safety
  1. Data Sharing
  • For private vehicles: Only consolidated and anonymized traffic data (e.g., aggregate counts, peak traffic times) will be shared with city departments, including LADOT and LAFD, to support infrastructure, safety, and emergency No personally identifiable ALPR information will be disclosed for this purpose.
  • For commercial vehicles: Vehicle data and images may be shared with city departments, such as LADOT and LAFD, to support infrastructure, safety, and emergency planning related to commercial traffic.
  1. Law Enforcement Access and Disclosure Limitations
    • ALPR data is not automatically shared with law
    • The system is not connected to any government
    • Only the Los Angeles Police Department (LAPD) may request
    • LAPD may not directly access the ALPR system or search its
    • Requests from LAPD will only be considered if accompanied by a valid and active LAPD case number, and a description of the specific license plate(s), date/time frame, and incident under investigation.

Each request will be reviewed by LHHA’s authorized data administrator(s) and may be denied if it does not comply with these conditions.

  1. Who Can Access the Data

Access to ALPR information is logged, periodically audited and limited to:

  • Designated LHHA board members or authorized administrators
  • Technical personnel under contract
  • Third-party ALPR service providers under agreement with LHHA ensuring legal compliance
  1. Retention of ALPR Information
    • ALPR data is retained for no longer than 120 days, unless:
      • It is associated with a documented traffic or safety concern under review
      • A lawful preservation request has been made by LAPD with a valid case number
    • Data is retained only for limited purposes and is not available for general discovery without
  1. Security Safeguards

LHHA and its service providers use industry-standard safeguards including:

  • End-to-end encryption of data during transmission and storage
  • Access controls and administrator audit logs
  • Security protocols to prevent unauthorized access
  1. Individual Rights and Requests

You may request any ALPR information collected about your vehicle by submitting a written request to Lake HHA as shown in Section 11.  Your request must include:

  • License plate number
  • Approximate date/time of travel
  • Proof of vehicle ownership or authorization
  • Government-issued photo ID

In accordance with our third-party data management agreement, a fee not in excess of $100 will be charged to cover the direct costs of data retrieval and processing. This fee is necessary to reimburse the Association for the actual expenses incurred by our consultant to manually retrieve, redact, and provide the specific records requested. The Association will provide an invoice and a copy of the consultant’s fee for your request upon receipt of a verified request.

LHHA will respond to verified requests within 30 days of receipt of payment.

Third-Party Service Providers

LHHA may use third-party ALPR vendors under written agreements requiring:

  • Compliance with California privacy
  • No resale, reuse, or repurposing of data
  • Strict access and breach reporting protocols
  1. Policy Review and Transparency

This policy will be reviewed annually by the LHHA Board and updated as needed. Residents will be notified of any material changes. The current version of this policy is available at LakeHHA.Org

  1. Contact Information

For questions or concerns about this policy or the ALPR system, contact:

Lake Hollywood Homeowners Association: Info@LakeHHA.Org